NAAA recently submitted comments on a petition from American Drone LLC seeking to amend their existing exemption to conduct “Limited” Beyond Visual Line-of-Sight (BVLOS) Part 137 Operations with an Uncrewed Aircraft System (UAS). 

 

The proposed BVLOS operations would take place within application sites wherein portions of the site are “hidden by topology or surrounding trees and a direct line of sight is not practical to obtain." While neither the remote pilot-in-command (RPIC) nor the visual observer (VO) will maintain line-of-sight with the UAS, American Drone did state that the airspace above and beyond the defined fields in which it was treating as well as the UAS’ flight paths from take-off/landing areas to the point above the field in which the UA will descend into BVLOS would  be visible to both its RPIC and VOs. 

 

While acknowledging the impracticality of maintaining line-of-sight in hilly fields or those with irregular shapes and tree lines, NAAA’s comments centered on ensuring the safety of crewed Part 137 operations. NAAA expressed concern over the scope of BVLOS permitted and maintains the need to define more clearly what “Limited” BVLOS would entail. 

 

NAAA further reiterated the need for detect and avoid (DAA) technology which is certified by the FAA as effective against both cooperative (ADS-B equipped) and non-cooperative aircraft. Because the petitioner would be conducting the same type of operations (Part 137) and in the same seasonally congested regions/airspace, crewed aerial application operators will be the primary mid-air collision risk-bearers. 

 

You can view NAAA’s full comments here.